M&A involving Foreign Corporations

Being on the west coast, much of my work has an international component. Foreign and international tax transactions can be particularly complex. There are many “gotchas” that make these transactions difficult to manage. Non-tax lawyers often deal with foreign tax-sensitive transactions but sometimes the client would be much better served if a tax lawyer is…

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Tax Free Mergers and Reorganizations in California: Continuity of Interest

As noted in an earlier post, some types of acquisitions can be tax free or tax deferred to the sellers. In order to determine whether the tax-free reorganization provisions are available, the type of currency being given to the sellers in exchange for their stock or assets must meet certain requirements. The “currency” could be in…

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Tax Free Mergers and Reorganizations in California: Continuity of Interest

Tax Free Mergers and Reorganizations in California: Continuity of Interest.

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Buying and Selling a Business: Mergers and Acquisitions: Tax Issues

A sale or acquisition of a company may take the form of a tax free reorganizations or a taxable transactions. How should we analyze, structure, and negotiate the tax provisions when a client wants to sell a company? The first question will almost always be whether the seller can avail itself of the tax-free provisions of…

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